Consultation input to NOU 2026: 1 A sustainable municipal sector

The Lion Mothers have submitted consultation input to NOU 2026: 1 A sustainable municipal sector. We are concerned that the proposals in the report place too much emphasis on efficiency and flexibility, without sufficient assessment of the consequences for legal certainty and equal services. Children with illness and functional variation and their families in particular risk being severely affected. Sustainability cannot be achieved at the expense of fundamental rights.

Below you can read the consultation submission in its entirety:

Consultation input - NOU 2026: 1 A sustainable municipal sector

Løvemammaene is a diagnosis-independent organization that works to inform about and improve the rights of children and young people with illness and functional variation. We are passionate about support, freedom and equality for the entire family. The organization is growing, and we are approaching 10,000 members.

The Lion Mothers would like to thank you for the opportunity to provide input. We have chosen to comment on selected proposals from the commission's work, as presented under points 1-5 below.

At the outset, we would like to point out that it is often pointed out that we «"We're running out of personnel before we run out of money"», and that recruitment is the biggest challenge in the municipal sector. Recruitment is important, but the reality is that municipal finances are the biggest problem. The municipalities' room for manoeuvre is largely determined by state transfers. At the same time as the Norwegian state has never been richer, and significantly richer than comparable European countries, many municipalities are running a deficit. Norway should have all the prerequisites to offer the best health and care services, both municipally and in specialist health services.

The Commission assumes that reduced state control and increased local room for manoeuvre will contribute to more efficient use of resources and better utilisation of personnel resources. The Lionesses believe that this premise is not sufficiently addressed. The Commission itself points to significant variation in compliance between municipalities, with levels ranging from approximately 50 to 99 percent. The Lionesses believe that reduced state control and fewer national requirements could reinforce existing differences and increase the risk that rights are not fulfilled.

For families with seriously ill children, experience shows that reduced governance often leads to increased arbitrariness, greater geographical disparities and weakened legal certainty. There is insufficient documentation of how the proposed measures will affect the most vulnerable groups in society.

The Commission also points to the need to mobilize labor in the years ahead. The Lion Mothers would like to emphasize that families with seriously ill children and children with disabilities already constitute a significant and often invisible part of care work in Norway. Inadequate services today lead to far too many parents reducing or dropping out of the workforce. A weakening of services could therefore exacerbate – not reduce – the challenges related to labor in the municipal sector. Sustainability is not just about finances and personnel. Sustainability must also be understood in light of equality and human rights.

About the CRPD and the best interests of the child

The State Administrator of Rogaland clarifies in his guidance on the CRPD in individual cases under the Health and Care Services Act , dated 15.03.26 that the CRPD is based on an important change in the approach to how society should meet children and adults with functional variations. The CRPD states that the general human rights apply fully to people with functional variations.

And a further common thread in the CRPD is that it aims to bring about a paradigm shift in the approach to people with disabilities, from a medical approach to a rights-based approach. This means that professionals should move away from assessments of what is in the person’s «best interests» to a mapping of the person’s wishes. Self-determination is therefore a central part of the convention.

It is striking that the NOU is so little directed at children and their families. We find no trace of assessments of the best interests of the child or assessments of child rights in the work on a sustainable municipal sector. This is problematic, since under both Norwegian law and the Convention on the Rights of the Child there is an obligation for ministries, directorates, counties and municipalities to assess the best interests of the child before decisions are made that affect children, whether they concern individual children, groups of children or children in general. The Lion Mothers believe this is a significant weakness in the report, and assume that the best interests of the child are given significantly greater space in the further follow-up of the commission's work.

The Commission notes that it will continue to monitor the process of incorporating the CRPD into Norwegian law. This process is now underway and it is important that the Convention becomes the guiding principle for a sustainable municipal sector in the future.

1. Dismantle the teacher norm

The Commission's proposal to phase out the learning norm is of great concern to the Lion Mothers. For children with illness and functional variation, teacher density, competence and predictability in school are crucial for learning, coping and inclusion. Many of these children already have a vulnerable educational offer, and reduced adult density will particularly affect children in need of extra support and adaptation.

The teacher norm has been an important minimum safeguard to ensure that municipalities do not reduce teacher density to a level that compromises students' right to education. Without such a norm, we fear that financial considerations will take precedence over children's needs to an even greater extent, and that the differences between municipalities will increase further. This would be contrary to the principle of equal services and the right to education.

The Lion Mothers believe that a sustainable municipal sector cannot be built by weakening the basic framework for children's education. Investing in children early is both economically profitable and absolutely necessary to prevent exclusion later in life.

2. Remove competency requirements in health and care services

The Commission's proposal to remove statutory competence requirements in health and care services will have serious consequences for citizens and their relatives. The proposal will weaken the quality of primary health care and contribute to increased differences between municipalities.

The Commission justifies the proposal by saying that the current competence requirements limit the municipalities' room for manoeuvre. The Lion Mothers believe that this is a wrong starting point when the goal is equal services. The obligation to comply with human rights cannot be made conditional on finances or local capacity. Municipal self-government cannot be based on the fact that it is too demanding or costly to include certain groups in the community, this would in practice entail an erosion of fundamental rights.

The Commission itself acknowledges that removing competence requirements may have negative consequences for certain groups, but emphasizes the need for flexibility. The Lion Mothers believe that considerations of flexibility cannot take precedence over citizens' rights to quality, accountability and real participation. Weakening the competence requirements will create a serious competence gap, which will affect many citizens, even in small municipalities.

The Office of the Auditor General has already documented significant geographical disparities in the provision of health and care services. Removing the competency requirement will exacerbate these disparities by leaving crucial competencies lacking in many municipalities.

The Lion Mothers believe that removing the competency requirement is a very serious step in the wrong direction. The Lion Mothers assist a large number of member families each year. Many of them already experience that the municipalities are unable to offer adequate services and it takes several years of repeated complaints to get the necessary help in place. For several families, the help comes far too late. The consequences are parents who drop out of the workforce, siblings who struggle, and families who do not receive the support they need to experience coping and participation. It costs money to ensure competency and quality – but it costs far more to deal with the consequences of having failed afterwards.

3. Incorporate, merge and simplify earmarked grants

The Lion Mothers would like to emphasize that earmarked grants are often crucial for state initiatives to actually reach the target group, and are an important management tool from the state towards the municipality. Experience shows that when funds are incorporated into the framework grant, less is transferred than what it actually costs the municipality, and they are not necessarily used for the purpose for which they were intended. Earmarking is therefore not an obstacle to sustainability, but an important management tool to ensure quality, legal certainty and goal achievement.

4. Dismantle the primary school subsidy in the income system

The Commission justifies the proposal by saying that the subsidy could provide adverse incentives in the organization of the school structure. The Lion Mothers would like to emphasize that the decisive factor is not the model itself, but the consequences for children in need of adaptation. The best interests of children must be given decisive weight when making changes to the income system, and we lack a clear assessment of this proposal in terms of child rights.

5. Simplification of investment subsidies for care homes and nursing homes

The investment subsidies that municipalities can receive through the Housing Bank, including through the establishment of housing cooperatives, are crucial for many of our member families. This model gives young adults with functional variations the opportunity to own their own home, while at the same time receiving necessary health and care services.

The lionesses question the commission's presentation of the housing cooperative model as the most costly form of housing for the municipalities. Calculations from the Housing Bank show that this is not correct. There is a significant discrepancy between the Housing Bank's documented advantages of the model and the commission's description of the subsidy scheme.

Furthermore, the commission questions the current requirements related to the investment subsidy, including that care homes should not have an institutional-like character, should be located in ordinary living environments, should not be too large, and that user groups should not be co-located in an unfortunate manner. The commission claims that such requirements increase staffing needs and limit the municipalities' flexibility.

The Lion Mothers react with great concern to these statements, and believe that the Commission's proposal to remove the requirements is in direct violation of the CRPD. We cannot develop a sustainable municipal sector where some are kept outside of basic human rights. With these proposals, we are back to the time before the HVPU reform in 1991. A sustainable municipal sector cannot be developed by weakening the right to live independently and with dignity.

If the simplification of the subsidy is implemented, without clear requirements for rights for the target group, Løvemammaene fears that many of our member families will end up in a loop between the right to choose where to live and the right to necessary health and care services. And if municipalities are pressured to consider these two conditions separately, it is far from sustainable for both the municipality and the citizen themselves.

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The Commission highlights the need for restructuring and efficient use of resources in the face of tighter financial conditions and increased demand for services. The Lionesses would like to conclude by emphasizing that sustainability in the municipal sector cannot be understood narrowly as efficient use of resources alone. Transformations cannot be carried out at the expense of legal certainty, equal services and children's fundamental rights. A municipal sector that does not ensure children and families real participation and necessary services is not sustainable - neither socially, economically nor humanly.

The Lionesses would recommend that in future work, particular emphasis be placed on:

The CRPD and the principle of the best interests of the child, including the right to self-determination, as guiding principles before structural changes are implemented.